Re: Proposed Refurbishment and Continued Operation of Darlington Nuclear Generating Station

Dear Commission Members:

I’m writing to express my concerns with Ontario Power Generation’s (OPG) plans to refurbish and keep the Darlington nuclear reactors running until 2055.

I believe the Environmental Assessment report has failed to properly address a number of concerns regarding the continued operation of the Darlington nuclear station.

1. Environmental damage and risks to Lake Ontario

The Darlington Nuclear Generating Station (DNGS) uses Lake Ontario as a source of cooling water and a dump for its waste water. It is also a major source of thermal and chemical pollution in the lake. This causes significant harm to aquatic ecosystems, killing millions of fish and damaging fish habitat.

Between 2006 and 2008, OPG estimates DNGS killed between 15,000 and 26,020 fish. Fish kills appear to be increasing., with a recently study by P.A. Henderson estimating that Darlington was responsible for killing 274,931 fish in 2010/2011.

OPG also estimates that Darlington’s cooling system sucked up 15,631,833 fish eggs and 1,201,943 larvae in 2004. When the loss of fish eggs and larvae are counted, DNGS’s once-through cooling system kills millions of fish annually.

The Department of Fisheries and Oceans admitted in 2011 that Darlington’s impact on fish populations, heat pollution and the ongoing release of chemicals contravenes the Fisheries Act. This is unacceptable.

The Draft Screening Report from CNSC indicates that storm water runoff from the DNGS contains tritium, copper, lead, zinc, manganese and other toxic metals. The report also indicates that both coliform and phosphorus levels exceeded relevant benchmarks. On-site water bodies and samples of water from the portions of Lake Ontario closest to the DNGS exceed Provincial Water Quality Objectives. Yet, DNGS is not subject to any on-going requirement to monitor and report storm water quality. This is irresponsible and may compromise public health.

Before receiving any approvals to proceed, OPG must have plans in place to mitigate thermal and chemical pollution, fish kills and storm water discharge in Lake Ontario. At a minimum, OPG must explore alternative technologies at DNGS such as closed-cycle cooling to mitigate damage to Lake Ontario from its operations.

2. Accident Risk and Emergency Planning

OPG’s Darlington NGS Risk Summary Report indicates that accidents involving large radiation releases are realistic at the DNGS. A more thorough and rigorous analysis of risks and emergency planning should take place before proceeding with any approvals for the DNGS.

Significant nuclear accidents are happening around the world about once per decade. It is essential that Canada require the highest level of risk assessment and safety protocols, especially since reviews of nuclear accidents at Three Mile Island, Chernobyl and Fukushima demonstrate that institutional failures and human error are contributing factors.

Given the catastrophic risks associated with nuclear accidents, especially on the doorstep of Canada’s most populated region, I am deeply concerned about insufficient emergency planning procedures at Darlington. We must ensure that rigorous emergency plans are in place and explore whether safer alternatives are feasible and available.

In addition, the nuclear industry must be held accountable for risks. Clearly OPG considers accidents leading to large radiation releases at Darlington a realistic possibility. Because of this fear, OPG has asked for and received special legislation to limit compensation for victims in the event of a large scale accident. The Nuclear Liability Act (NLA), means that in the event of an accident OPG would not pay more than $75 million for environmental clean-up or victim compensation. The NLA also completely absolves OPG’s suppliers from compensating victims even if the negligence of those suppliers causes the accident.

Failure to hold the nuclear industry accountable for risks misrepresents the economics of nuclear power and is a disincentive to creating rigorous risk avoidance policies. Other forms of power generation are responsible for the full cost of their mistakes, why not the nuclear industry? Accountability is essential if the industry is to take the full scope and magnitude of nuclear risks seriously.

Government must act to ensure that public safety is a top priority. How can this be achieved when large scale accidents are not considered in the environmental review of OPG’s proposal to extend the life of the DNGS?

Before OPG is allowed to proceed with their proposal to rebuild and extend the life of the DNGS, a public review of potential large scale accidents at Darlington must take place. OPG and its suppliers should assume financial responsibility for accidents and mistakes.

3. Nuclear Waste Management and Decommissioning

The nuclear industry has not finalized a comprehensive plan for dealing with nuclear waste. Meanwhile, the amount of dangerous nuclear waste continues to grow. Whether the method chosen for long-term storage of waste is deep geological storage or interim storage on site, OPG is unfairly placing the burden to monitor this waste on future generations.

Further complicating this issue is OPG’s continued plans to ship waste from the DNGS to Bruce Nuclear Generating Station. OPG provides inadequate consideration of the potential for sabotage of shipping containers, transportation accidents, or radioactive release during routine transportation.

OPG has also failed to provide adequate plans for decommissioning reactors at the DNGS. Approvals for the DNGS should not be granted without proper plans and cost estimates for decommissioning or radioactive waste disposal. In the UK, costs for decommissioning and waste disposal continue to skyrocket. Media reports suggest these costs will likely exceed the capital cost to build the reactors in the first place.

As the risks and costs associated with waste management and decommissioning skyrocket, it is unacceptable and irresponsible to place this burden on our children and future generations.

4. Financial Costs

No nuclear project in Ontario’s history has come in on budget or on time. The existing Darlington reactors were supposed to cost $4 billion, but came in $10 billion over budget.

In 2007 the Ontario Power Authority (OPA), said it would cost $6 billion to build two new reactors at Darlington. The McGuinty government suspended the purchase of new reactors in 2009 when the cost estimates came in at $20 billion more than the original estimate of $26 billion.

The recent refurbishment at Bruce nuclear is $2 billion over budget and 3 years behind schedule.

The estimated cost of rebuilding CANDU reactors has ballooned over the past decade from approximately $800 million per reactor in 2002 to $2.5 billion per reactor today.

Ontario rate payers are still paying for the debt associated with previous nuclear projects. It is unacceptable and irresponsible that the Ontario government has no plans in place to protect ratepayers or taxpayers from further nuclear cost overruns.

It is inconceivable that the Ontario government has not conducted an independent review of nuclear costs or alternatives. Indeed, over the past 7 years the Ontario government has prevented any public reviews of the need for, or alternatives to, nuclear power at Darlington.

The cost estimate to refurbish the DNGS vary widely from $8 to $14 billion. And none of these estimates have been evaluated by an independent third party.

The DNGS rebuild should not proceed before a transparent and independent review of costs and alternatives takes place.

Conclusion

I am strongly opposed to OPG’s plans to refurbish and continue to operate the Darlington nuclear reactors until 2055. The risks and costs of nuclear are too high to justify.

More affordable, reliable and safer alternatives to nuclear exist. The Darlington refurbishment should be halted until the need for, alternatives to, and environmental effects of nuclear are fully and independently considered.

I would also like the opportunity to provide an oral presentation to the CNSC at your scheduled hearings on November 13 and 14, 2012.